Hi Everyone,
 
I hope some of you may be able to assist us.
 
We use a third-party vendor for disposing of paper records.  They also
provide a paper recycling service for us.  
 
We have two different types of bins.  Locked bins and desk-side recycled
bins.
 
Locked bins must be used by all associates to dispose of records that
contain HIPAA, PI or sensitive company information.  The bins are
located throughout our company.  The desk-side recycle bins are at every
associates desk.  They use these bins to dispose of any materials that
can be recycled.
 
It was recently brought to our attention that our vendor is taking the
paper materials out of the desk-side recycle bins, opening up the locked
bins and disposing of the paper material in the locked bins. 
 
It has also been brought to our attention that the locking mechanism on
the locked bins is cheap and a stronger lock should be used.
 
Are there any guidelines as to the type of locking mechanism that should
be used and who should have access to unlock the bins?  Also, should we
stop allowing the vendor to open up the locked bins while at our
facility?
 
Thank you, all
 
Donna Malzone l Records and Information Consultant
Blue Cross and Blue Shield of Massachusetts, Inc.
401 Park Drive
Boston, MA  02215
(P) 617 246-3534 l (C) 781 760-5754
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